The Weekly Law Reports
[2022] 1 WLR 2277
Court of Appeal
*Charman v Revenue and Customs Commissioners
[2021] EWCA Civ 1804
2021 Nov 17, 18; Dec 3
Green, Arnold, Snowden LJJ
Revenue— Income tax— Employment— Earnings— Employer granting taxpayer options to purchase shares in company— Options vesting in three tranches— Taxpayer resident in United Kingdom when first two tranches vesting but not third— Whether taxpayer liable to tax in respect of third tranche— Whether taxpayer resident in United Kingdom when third tranche of options acquired— Whether “acquisition” of options occurring when options granted or when options vesting—
Income Tax (Earnings and Pensions) Act 2003 (c 1), ss 420(8), 474(1), 476